Privacy Policy — Zen Garden

Last updated: 5 October 2026

1. Introduction

Zen Garden is an extended reality (“XR”) experience developed by AlterEyes NV (“AlterEyes”, “we”, “our”, or “us”) on behalf of PICO, for PICO XR devices.

AlterEyes respects your privacy. This Privacy Policy explains what information Zen Garden accesses or processes when you use the application, why this information is used, and where it is processed.

Zen Garden uses certain XR features of your PICO device, including hand tracking, eye tracking, and information about your physical surroundings. These features require sensor data to be processed in order for the experience to function.

Zen Garden processes this XR tracking and spatial information locally on your PICO device. Zen Garden does not transmit this information to AlterEyes or to any third-party service.

Zen Garden does not use analytics, telemetry, crash-reporting services, remote logging, user accounts, entitlement identifiers, advertising services, or networking services.

2. Data Controller

For any personal data processed by AlterEyes in connection with communications about Zen Garden, the data controller is:

AlterEyes NV
Vissersstraat 1 K6
3500 Hasselt
Belgium

Crossroads Bank for Enterprises (KBO/CBE): 0723.518.446

Email: info@altereyes.com

3. Information Used by Zen Garden

Zen Garden may access or process the following information provided by the PICO device and its XR system.

3.1 Hand Tracking

Zen Garden may use hand-tracking information to determine the position, orientation, and movement of your hands and fingers.

This enables you to interact naturally with objects and elements within the XR experience.

Hand-tracking information may include estimated positions and orientations of hand and finger joints and recognized hand poses or gestures.

This information is:

• used only to provide interactions within Zen Garden;
• processed locally on the PICO device;
• not transmitted by Zen Garden to AlterEyes or any third party;
• not remotely stored;
• not used to identify you;
• not used for advertising or profiling.

Zen Garden does not create or retain a biometric identity or biometric template based on your hands.

3.2 Eye Tracking and Gaze Information

On PICO devices that support eye tracking, Zen Garden may use eye-tracking or gaze information to determine approximately where you are looking within the XR experience.

This may include gaze direction, gaze position, eye pose, or related tracking information made available through the PICO XR system.

Zen Garden uses this information only where necessary for features of the XR experience.

Eye-tracking information is:

• processed locally on the PICO device;
• not transmitted by Zen Garden to AlterEyes or any third party;
• not remotely stored;
• not used to identify or authenticate you;
• not used for advertising, behavioral profiling, or marketing.

Zen Garden does not create or retain a biometric identity or biometric template from eye-tracking information.

3.3 Physical Environment and Spatial Data

Zen Garden may use spatial information about your physical environment to create and operate mixed-reality features.

Depending on the PICO device and system features being used, this may include information such as:

• the geometry or spatial mesh of the surrounding room;
• positions and dimensions of surfaces;
• floors, ceilings, walls, doors, windows, or other physical structures;
• detected or classified physical objects or furniture;
• spatial or scene anchors;
• the relative position of the headset within the physical environment.

This information allows virtual content to be positioned appropriately relative to your surroundings and enables interactions between the virtual experience and your physical environment.

Spatial information used by Zen Garden is processed locally on the PICO device.

Zen Garden does not transmit room geometry, spatial meshes, scene information, spatial anchors, or other information about your physical environment to AlterEyes or to any third party.

Some spatial information may be generated, managed, or stored locally on the device by the PICO operating system or PICO’s system-level spatial services. Such processing is performed by the PICO platform rather than by AlterEyes and is subject to PICO’s own terms and privacy practices.

Zen Garden does not use spatial information for advertising, profiling, or determining your postal address or real-world identity.

3.4 Headset and Controller Tracking

Like other XR applications, Zen Garden uses information about the position and orientation of the headset and, where applicable, controllers or other input devices.

This tracking information is necessary to render the XR experience correctly and respond to your movement.

This information is processed locally on the device and is not transmitted by Zen Garden to AlterEyes or to any third party.

4. Camera and Sensor Data

PICO XR devices may use cameras, depth sensors, motion sensors, and other hardware to perform tracking, eye tracking, hand tracking, and spatial understanding.

Zen Garden relies on tracking results and spatial information made available by the PICO platform for the functionality described in this Privacy Policy.

Zen Garden does not transmit images, video, or sensor data from your physical environment to AlterEyes or to any third party.

Underlying sensor processing performed by the PICO operating system or device is controlled by PICO and is subject to PICO’s own privacy terms and device settings.

5. Purpose of Processing

Zen Garden uses the information described above solely to provide and operate the XR experience, including to:

• track the user’s position and movement in XR;
• enable hand-based interaction;
• enable gaze-based functionality;
• position virtual objects appropriately;
• understand relevant geometry of the user’s physical environment;
• support interaction between virtual content and the physical environment;
• provide functionality necessary for an immersive XR experience.

Zen Garden does not use this information for analytics, advertising, direct marketing, user profiling, behavioral tracking, or automated decision-making.

6. Local Processing and Data Transmission

The XR tracking and spatial data described in this Privacy Policy is processed locally on your PICO device.

Zen Garden does not transmit application data to AlterEyes or to third-party servers.

In particular, Zen Garden does not transmit:

• hand-tracking data;
• eye-tracking or gaze data;
• headset movement or pose data;
• controller tracking data;
• room scans;
• spatial meshes;
• scene anchors;
• detected room geometry;
• information about furniture or objects detected in your physical environment;
• usage analytics;
• telemetry;
• diagnostic or crash-reporting information; or
• logs.

Zen Garden does not use network functionality to send this information elsewhere.

7. Storage and Retention

Zen Garden does not remotely store hand-tracking, eye-tracking, headset-tracking, controller-tracking, or physical-environment data.

Information required for XR functionality may temporarily exist in application memory while Zen Garden is running.

The PICO operating system may independently maintain spatial information, permissions, anchors, maps, or related device-level data locally on the headset in order to provide its XR and spatial-computing functionality.

Such device-level storage is controlled by the PICO operating system and is subject to PICO’s own privacy practices.

Zen Garden does not maintain a remote database of user information or XR tracking data.

8. Accounts and Identifiers

Zen Garden does not require or provide a user account.

Zen Garden does not collect or transmit PICO account identifiers, entitlement identifiers, advertising identifiers, or other persistent user identifiers.

Zen Garden does not attempt to identify individual users.

9. Permissions

Zen Garden may request device permissions necessary to access XR capabilities such as eye tracking, hand tracking, or spatial information.

Permissions are requested solely for the functionality described in this Privacy Policy.

Where the PICO operating system provides controls for these permissions, you can deny or withdraw them through your device settings.

If a required permission is denied or withdrawn, the corresponding feature of Zen Garden may not function correctly or may become unavailable.

10. PICO Platform

Zen Garden is designed for and operates on the PICO platform.

PICO provides the operating system, hardware functionality, XR APIs, and platform services on which Zen Garden runs.

PICO may independently process information at the device or platform level. Such processing is performed by PICO rather than by Zen Garden or AlterEyes.

AlterEyes does not control processing independently performed by PICO.

For information about PICO’s processing of personal data, please consult the privacy notices and settings provided by PICO for your device and region.

11. Third Parties

Zen Garden does not integrate third-party analytics, advertising, telemetry, crash-reporting, logging, networking, or user-account services.

Zen Garden does not sell personal data.

Zen Garden does not transmit hand-tracking, eye-tracking, headset-tracking, controller-tracking, room, or spatial information to third parties.

PICO is the provider of the device platform and operating system. Any processing performed independently by PICO is governed by PICO’s own privacy terms.

12. Communications with AlterEyes

Zen Garden itself does not transmit personal information to AlterEyes.

If you choose to contact AlterEyes separately, for example by email, we will receive the information that you voluntarily include in that communication.

We may use that information solely to respond to your inquiry, provide support, comply with legal obligations, or handle another matter you have contacted us about.

This processing takes place independently from Zen Garden itself.

13. Your Privacy Rights

Depending on where you live, applicable data-protection law may provide rights concerning personal data processed by AlterEyes. These may include the right to:

• request access to your personal data;
• request correction of inaccurate personal data;
• request deletion of your personal data;
• restrict certain processing;
• object to certain processing;
• receive certain personal data in a portable form; and
• withdraw consent where processing is based on consent.

You can contact us at info@altereyes.com to exercise applicable rights.

Because Zen Garden’s XR tracking and spatial data is not transmitted to AlterEyes, AlterEyes does not hold a server-side copy of that information that could be accessed or deleted.

Device-level information and permissions can be managed through the settings available on your PICO device.

You also have the right to lodge a complaint with the competent data-protection supervisory authority. In Belgium, this is the Belgian Data Protection Authority.

14. Children’s Privacy

Zen Garden does not knowingly collect or transmit personal information from children.

The application does not create user accounts or remotely store hand-tracking, eye-tracking, spatial-environment, or other user information.

Use of the PICO device, PICO account, and associated age requirements is additionally governed by PICO’s terms and parental or age controls.

If you believe that AlterEyes has received personal information relating to a child through a separate communication concerning Zen Garden, please contact us at info@altereyes.com.

15. Security and Privacy by Design

Zen Garden has been designed so that XR tracking and spatial information required for the experience remains on the device rather than being transmitted to AlterEyes or third-party services.

The application does not include analytics, telemetry, remote logging, crash-reporting services, advertising SDKs, networking services, or user-account systems.

This local-processing approach reduces the amount of personal information that leaves the user’s device.

16. Changes to This Privacy Policy

We may update this Privacy Policy if Zen Garden’s functionality, applicable law, or PICO platform requirements change.

If an update materially changes how information is processed, we will update this notice and take any additional measures required by applicable law.

The date at the top of this Privacy Policy indicates when it was last updated.

17. Contact

For questions, requests, complaints, or other inquiries regarding privacy and Zen Garden, contact:

AlterEyes NV
Vissersstraat 1 K6
3500 Hasselt
Belgium

Email: info@altereyes.com